The benefits of wild caught salmon compared to the health and environmental risks of farmed fish was presented in "Wild Salmon Don't Do Drugs" (TLfDP #235/236, Feb/March 2003 issue). This discussion will highlight additional threats from biotechnology in the fishing industry and the need for consumer advocacy.

The American food supply is currently bombarded with genetically engineered soy, corn, potatoes, dairy products, and more, with no labels informing the consumer of these controversial experimental foods. The fish industry is now pushing for approval of transgenic or genetically engineered (GE) fish.

After decades of carelessly polluting the oceans with toxic run-off, oil spills, and global warming, man is now purposefully seeking to alter the aquaculture in a way that could have devastating consequences for generations to come. Fishing companies want to market GE salmon capable of growing faster and larger than wild fish, claiming this will help feed the world's burgeoning population. Critics and conservatives fear this scientific experiment could backfire and actually wipe out all the native stock, with dire consequences to the entire aquaculture.

Accidental Discovery
Genetically engineering salmon came about by accident 20 years ago when a Newfoundland researcher froze a tank full of flounder, and surprisingly the fish survived. Flounder and other fish from the icy waters of Canada have genetically adapted to thrive in their cold environment. Researchers found a protein that prevents these fish from freezing, and it became known as the "antifreeze" gene.¹

Canadian scientists attempted to splice the antifreeze gene into Atlantic salmon with the idea that salmon farms could be developed in colder waters. The antifreeze splicing was not successful. However, scientists learned this gene also controls growth. The genetic material is injected into salmon eggs and alters the fish's growth hormones, enabling those hormones to be produced by the liver and pituitary gland. That change greatly accelerates growth, causing GE fish to grow two to three times faster and much larger than normal, which has led some critics to coin the term, "Frankenfish." Critics emphasize that no testing of transgenic foods has been done.^1,2

In addition to salmon, transgenic tilapia, trout, and carp are now being experimented with for the commercial market.²

Safety Factor
Are genetically engineered fish safe to eat? No one is sure. It is known that excessive growth results in deformities of the head and jaw that could easily be passed on to wild stock during breeding. The FDA is limiting its review of GE fish as a "New Animal Drug," and not as a "food" product for humans.²

The technology is so new there are no laws, regulations, or guidelines in place to protect public health. Once approved, there is no turning back. Contrary to industry promises of containment, real life situations have proven containment is a fantasy, not a reality. Escapes from fish farms have become routine and impossible to prevent. Another doubtful promise from industry is that GE fish will be sterile and pose no problem to wild stock. Cautious scientists believe there is no such thing as a 100% guarantee of sterility given the great possibility for human error and natural variation.²

The A/F Protein Company of Massachusetts claims to have back orders for 15 million eggs. It would only take a handful of those to be fertile to potentially destroy natural populations of wild stock. The stakes are high. At present there are no national or international regulations in place to protect the environment and human health from potential risks associated with transgenic fish.²

The US Food and Drug Administration (FDA) is the first regulatory agency in the world to receive an application to approve the commercial development of GE fish. Environmental advocates feel this is entirely inappropriate because the FDA has no relevant environmental experience and should not be deciding on international issues that affect the world's oceans and a major food source.² It is also possible that another country would permit GE fish farms even if the US does not. Threats to the environment and food supply would still remain.

The National Academy of Sciences (NAS) warns that using genetic engineering to alter animal production and growth could negatively impact the food supply and create new risks for public health and the environment. The FDA has asked the authors of the NAS report, "Animal Biotechnology: Identifying Science-Based Concerns," to identify issues of concern associated with the new field of genetic engineering.²

GE salmon that grow faster and larger than normal fish were found by Purdue scientists to have mating advantages over wild species. But their offspring suffer one-third greater mortality rate because of the impact of added genetic material. The Purdue scientists predict the introduction of GE fish could cause extinction of native species within only a few generations.³

Designed for rapid growth, transgenic fish have voracious appetites that scientists believe will out-compete wild stock for food when GE fish escape from their contained environment.² Scientists from the Royal Society of Canada say such rapid growth could increase insulin and other chemical compounds in GE fish. No one knows how the constant production of growth hormone might affect the fish, or the people who eat them.⁴

The technology has already produced GE (or cloned) dairy cows, chickens, pigs, and beef cattle, though not yet on a commercial scale. The NAS study specifies that GE fish may present the greatest environmental threat since penned fish cannot be fully contained and frequently break out, mixing with wild stock.²

Transgenic fish have been genetically engineered to contain certain desired traits. Biotechnologists have transferred genetic material from other fish, humans, and insects. Besides health and safety issues, there are moral issues to consider. Industry scientists appear to be in a frenzy with more than 35 species of GE fish being developed around the world.³

It brings to mind the post-WWII "atoms for peace" campaign to construct nuclear power plants with no thought to the health risks associated with living downwind from an operating plant and the as yet unresolved problem of nuclear waste disposal that eminent scientists promised would be in place long ago. Just like the nuclear issue, the technology for creating genetically engineered foods greatly exceeds man's ability to understand the long-term consequences to human health and the environment, or the ability to undo potential damage caused by the new technology.

Meticulous multi-generational, multi-species lab studies need to be performed to discern even the subtlest effects on growth and development from consuming GE foods. It is irresponsible for industry to make unsubstantiated claims that GE foods are essentially no different than non-GE foods.

Who's Regulating the Regulators?
The FDA is the only regulatory agency currently reviewing the licensing of GE fish, however, the FDA is woefully lacking in expertise to recognize potential impacts on human health and the marine ecosystems that may be irrevocably ruined by the introduction of GE fish into commercial aquaculture.⁵

Because there are no federal laws designed to govern the regulation of genetically engineered animals grown for human consumption, the FDA decided to review transgenic fish under "new animal drugs." To receive FDA approval, producers must complete a New Animal Drug Application (NADA), and demonstrate the safety and effectiveness of these fish.⁵

The Washington DC-based Center for Science in the Public Interest (CSPI) revealed that companies producing GE crops avoided answering questions and submitted erroneous data on federal applications aimed at ensuring the safety of bio-engineered foods before they are marketed. CSPI learned that FDA requests for additional information were frequently ignored, and even more startling, that the FDA overlooked factual and scientific errors in applications for GE tomatoes and cantaloupes.⁶

The unsuspecting consumer may be surprised to learn that industry determines how to conduct its own safety reviews and what information will be submitted. Since the FDA doesn't tell companies what to test for, many applications avoid including information on potential allergic or toxic reactions and nutrient content of the transgenic product.⁶

The FDA is continually giving approval for drugs that are later recalled for harming or killing hundreds of patients, however, attempts to recall transgenic fish that break loose from their pens and nets will be impossible. Einstein said, "Smart men solve problems, wise men avoid them." This is a problem that requires great wisdom.

With the revolving door policy of industry experts finding temporary employment at governmental regulatory agencies in order to facilitate approval for any number of industry demands, can we really trust our regulatory agencies to protect public health? With all due respect to the many honorable government representatives who do their best to fulfill their obligations, the sad reality is that the powerful influence of big business often overrides the noble efforts of honest men and women. Therefore, the responsibility falls to us as consumers to speak up on our own behalf, or suffer the consequences.

Greenpeace has initiated a protest at the development facility of the A/F Protein Co., and requested the FDA deny applications for the commercial sale of genetically modified fish. A moratorium on GE fish has been signed by dozens of scientists and fishing organizations including the American Society of Ichthyologists and Herpetologists; Canada's leading scientific body, the Royal Society; and Jean-Michel Cousteau, president of Ocean Futures.

Maryland was the first state to pass its own moratorium on the production of GE fish, followed by the state of Washington, which adopted sweeping new regulations to permanently ban GE salmon from fish farms in all its marine waters.^2,7

On May 9, 2001, a coalition of more than 60 petitioners, including environmental protection organizations, fishing companies and fishermen filed legal petitions with the FDA, Dept. of the Interior (DOI), Dept. of Commerce (DOC), Dept. of Defense (DOD), and Dept. of Agriculture (USDA), demanding a moratorium on the domestic marketing and importation of transgenic fish until the impacts to human safety and the environment have been adequately addressed.⁵

Canada's expert panel on the regulation of food biotechnology reviewed the ecological risks associated with the commercialization of GE fish that escape from net pens, and found there were significant uncertainties regarding threats to wild fish. The Royal Society has endorsed a moratorium on raising GE fish in aquatic net pens.⁸

Labeling Controversy
The labeling controversy began over a decade ago with the distribution of milk from cows treated with bovine growth hormone (BGH). The majority of consumers wanted BGH dairy products to be labeled. Industry won out and even sued a few small dairy farmers that dared to label their products "BGH Free." Hundreds of processed food items now contain by-products from GE corn and soy. The FDA has ignored consumer requests for adequate labeling of GE products, and given in to industry's refusal to do so.

Promoters of GE fish also refuse to label any such products. Another Washington based consumer advocacy group, Center for Food Safety (CFS), has filed a legal petition with the FDA demanding that all transgenic foods undergo independent human health and environmental testing. More than 600,000 consumers have sent comments to the FDA, the largest public response ever on a food issue. Comments can be submitted via www.foodsafetynow.org.⁴

Consumer Action
The Center for Food Safety has joined Clean Water Action and Friends of the Earth in taking legal action to prevent the environmental and health threats posed by GE fish. A legal petition has been filed demanding a moratorium on the sale or importation of GE fish into open waters, including ponds and net pens.⁴

A grassroots effort has been undertaken to encourage restaurants, grocers, and fish distributors to pledge their refusal to purchase or sell transgenic fish. As of February 20, 2003, a pledge to protect consumers and marine ecosystems from GE fish has been signed by 270 grocers, 173 restaurants, and 26 fish distributors from around the country. Consumer advocates who wish to join the campaign against transgenic fish can do several things:

1. Visit www.gefish.org to learn more about the issue
2. Write or call the FDA in support of the GE Fish Petition (a sample letter can be requested by calling 1-800-600-6664)
3. Encourage local chefs, restaurants, fish markets, and grocers to sign the petition which can be downloaded from www.gefish.org
4. Contact state representatives and senators about the need to ban GE fish from open waters
5. Call the FDA Center for Veterinary Medicine to express concern over approval of GE fish (301-827-3797). Check their website periodically for regional public meetings and attend if possible — www.fda.gov/cvm (in Hot Topics, click Biotechnology)

References
1. Genetic Engineering creates supersalmon — and controversy, Ecoglobe News, 12/2/99, http://www.ecoglobe.org.nz/news1999/d029news.htm. (02/04: Story no longer at this link. However, site has a wealth of information.)
2. Genetically Engineered Salmon: Q&A: Genetic Engineering: Greenpeace USA 10/30/02, http://www.greenpeaceusa.org/ge/fish_qa_text.htm.
3. Protect Our Waters from GE Fish! a consumer advisory from the Center for Food Safety.
4. Food Safety Now, a Publication of the Center for Food Safety, Summer 2002, Vol. One, No.1.
5. Executive Summary of The Center for Food Safety's Genetically Engineered Fish Legal Petitions, Campaign on GE Fish, http://www.stopgefish.org.(02/04, Web address now redirects to a porn site.)
6. Abboud, L., Makers of Modified Crops Faulted On Safety Data Submitted to FDA, Wall Street Journal, 1/7/03.
7. Genetically Engineered Fish Ban in Washington State Waters, Wild Matters (formerly Food & Water), Feb 2003.
8. Scientific Studies on Genetically Engineered Fish, The Center for Food Safety.

Health Risks and Environmental Issues
by Rose Marie Williams, MA
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845-255-0836 • Fax 845-255-5101

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